Redaction is one of the most critical steps in the DSAR process. When done incorrectly, the accidental release of third-party data turns a standard DSAR response into a severe data breach, often resulting in substantial fines. This guide highlights the three most common redaction mistakes and best practices to avoid them.
In a DSAR response, you must only provide the requester with their own personal data. You are legally required to withhold (redact) any personal data belonging to other living individuals (third parties) unless you have their explicit consent. Failure to redact properly is a breach of the third party's privacy rights.
This is the single most common, yet dangerous, error. Many users simply use a black box, highlighter, or marker tool within PDF editing software (like Adobe Acrobat or Preview) to obscure sensitive text.
The Risk: These tools often only create a visual layer on top of the text. If the recipient simply copies the text from the PDF and pastes it into a text editor (or uses certain accessibility tools), the underlying, sensitive third-party data is exposed instantly.
Best Practice: Use professional PDF redaction tools that permanently "burn" the redaction into the document, removing the underlying text completely. Adobe Acrobat Pro's proper redaction feature, or specialized redaction software, ensures the text cannot be recovered. Always test by attempting to copy text from the redacted area before sending.
Personal data is not just in the document content; it's often stored in the document's hidden properties, or metadata. This includes the author's name, creation date, editing history, internal comments, and the name of the last person who saved the file.
The Risk: A seemingly clean document may inadvertently reveal the name or email of a colleague (a third party) in the file properties. This constitutes an unauthorized disclosure, even though the content was properly redacted.
Best Practice: Before sending any documents, always check and remove metadata. In Adobe Acrobat, use "Remove Hidden Information" under the Tools menu. For Word documents, use "Inspect Document" under File > Info. Consider converting documents to a clean PDF format as a final step to eliminate hidden properties.
When searching large data sets, staff often focus solely on searching text documents (emails, Word files). They overlook personal data that may be embedded in non-textual formats.
Examples:
The Risk: If you miss these types of files, you are non-compliant. If the file contains unredacted third-party information, it is a breach.
Best Practice: Create a systematic review process that includes all file types. Visually inspect every document, image, and recording. For images containing third-party data, use image editing software with proper redaction capabilities. Consider whether the entire file needs to be excluded rather than partially redacted if the risk is too high.
While DSAR Helper doesn't perform automated redaction (which requires careful human judgment), it helps you maintain a systematic, compliant process:
Redaction requires careful human judgment and proper tools. A single redaction mistake can lead to an ICO complaint, a potential fine, and irreparable damage to your business's reputation.
Protect your compliance record by implementing a systematic review process, using professional redaction tools, and never rushing through this critical step—even when approaching the 30-day deadline.